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Regarding Docket No. Fr-6111-P-02, Hud’S Implementation Of The Fair Housing Act’S Disparate Impact Standard, Sonia Gipson Rankin, Alfred Mathewson, Melanie Moses, G. Matthew Fricke, Kathy Powers, Gabriel R. Sanchez, Christopher Moore, Elizabeth Bradley, Mirta Galesic, Joshua Garland
Regarding Docket No. Fr-6111-P-02, Hud’S Implementation Of The Fair Housing Act’S Disparate Impact Standard, Sonia Gipson Rankin, Alfred Mathewson, Melanie Moses, G. Matthew Fricke, Kathy Powers, Gabriel R. Sanchez, Christopher Moore, Elizabeth Bradley, Mirta Galesic, Joshua Garland
Faculty Scholarship
The is a Comment on the Department of Housing and Urban Development (HUD) Proposed Rule: FR-6111-P-02 HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard . This comment examines how algorithms in housing applications may be inherently biased against certain groups of people.
Their arguments against the proposed legislation:
1. To ensure that an algorithm does not have disparate impact, it is not enough to show that individual input factors are not “substitutes or close proxies” for protected characteristics.
2. It is impossible to audit an algorithm for bias without an adequate level of transparency or access to the …